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  5. 857 F.2d 881 (1988)
 

U.S. v. AYER

Nos. 88-1066, 88-1067.

857 F.2d 881 (1988)

UNITED STATES of America, Plaintiff, Appellee, v. Rita Kips AYER, et al., Defendants, Appellees, Universal Aircraft Corporation, S.A., Defendant, Appellant. UNITED STATES of America, Plaintiff, Appellee, v. Rita Kips AYER, Defendant, Appellant.

United States Court of Appeals, First Circuit.

Decided September 26, 1988.

Attorney(s) appearing for the Case

Edward B. Ginn and Kline & Gordon, Boston, Mass., on brief for Universal Aircraft Corp., S.A. and Rita Kips Ayer, defendants, appellants.

William S. Rose, Jr., Asst. Atty. Gen., Gary R. Allen, David I. Pincus, and Regina S. Moriarty, Tax Div., Dept. of Justice, Washington, D.C., on brief for plaintiff, appellee.

Before COFFIN, BOWNES and SELYA, Circuit Judges.

SELYA, Circuit Judge.

The stage was set for these appeals by the filing of an action to enforce certain federal tax liens in the United States District Court for the District of Massachusetts. The cast of characters, in no especial order, is as follows:

1. The taxpayers: Frederick B. Ayer and his wife, defendant-appellant Rita Kips Ayer.

2. The debt: upward of $820,000 in taxes, penalties, and interest, assessed against the taxpayers, jointly and severally...

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